National Protective Ins. v. Commissioner

128 F.2d 948, 29 A.F.T.R. (P-H) 748, 1942 U.S. App. LEXIS 3764
CourtCourt of Appeals for the Eighth Circuit
DecidedJune 30, 1942
DocketNo. 12216
StatusPublished
Cited by9 cases

This text of 128 F.2d 948 (National Protective Ins. v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Protective Ins. v. Commissioner, 128 F.2d 948, 29 A.F.T.R. (P-H) 748, 1942 U.S. App. LEXIS 3764 (8th Cir. 1942).

Opinion

JOHNSEN, Circuit Judge.

The question is whether petitioner is entitled to be classified as a “life insurance company” for income tax purposes, or whether it is subject to be taxed as “an [949]*949insurance company other than life or mutual”.

Petitioner made its tax returns as a life insurance company, under sections 201-203 of the Revenue Acts of 1934 and 1936, 48 Stat. 731, 49 Stat. 1710, 26 U.S.C.A. Internal Revenue Acts, pages 729-732 and 898-900. Section 201(a) of these acts defines a life insurance company, for income tax purposes, as follows: “When used in this title the term ‘life insurance company’ means an insurance company engaged in the business of issuing life insurance and annuity contracts (including contracts of combined life, health, and accident insurance), the reserve funds of which held for the fulfillment of such contracts comprise more than 50 per centum of its total reserve funds.”

The Commissioner challenged petitioner’s returns for the years 1935 and 1936, on the ground that it was not a life insurance company within the definition of section 201(a), since its reserves on its life insurance were far less in amount than those which it maintained on its separate health and accident insurance, and that it therefore constituted an insurance company other than life or mutual under the provisions of section 204, 26 U.S.C.A. Int.Rev.Acts, pages 732-734, 900-902, and was required to make its returns on the basis of that section. Deficiencies of $10,338.71 and $5,925.21, respectively, for the two years involved, were determined against petitioner under section 204. The Board of Tax Appeals upheld the Commissioner’s determination, 44 B.T.A. 978, and petitioner has appealed from the decision of the Board.

Petitioner was a stock insurance company, incorporated under the laws of Missouri, and engaged in writing health and accident insurance and life insurance, solely within that state, on a “stipulated premium” basis. Its separate health and accident business constituted more than 98 per cent of its total premium income, and its life insurance less than 2 per cent. Thus, in 1935 its health and accident premiums amounted to $636,631.18 and its life insurance premiums to only $11,647.15, and in 1936 these premiums were, respectively, $688,001.41 and $12,911.80.

Under section 5764, Mo.Rev.St.1929, Mo. R.S.A. § 5875, petitioner was required to maintain standard death reserves on its life insurance contracts, consisting of such amounts out of the premiums as, improved with interest at 3% per cent per annum, would discharge its contingent liabilities on the basis of the American Experience Table. These reserves aggregated $10,-037.89 in 1935 and $11,841.29 in 1936.

Petitioner had also set up unearned premium reserves on its health and accident business, amounting to $98,622.85 for 1935 and $121,114.45 for 1936, although the Missouri statutes made no prescription for any reserves on such policies. The reserves had been established, however, pursuant to a provision in petitioner’s articles of incorporation, and in accordance with a written agreement between petitioner and the State Superintendent of Insurance by whose terms the fund was to be built up and maintained in an amount equal to fifty per cent of the gross annual premiums on the health and accident business. This agreement recited that its purpose was to provide for the maintenance of unearned premium reserves on the part of petitioner, “equivalent to the reserves maintained by other companies doing a like business in this state” and on the basis “generally accepted and used by other insurance companies doing a like business”. The unearned premium reserves were made to appear and were carried as a liability in petitioner’s periodical reports to the state insurance department.

The foregoing facts quite clearly demonstrate that petitioner’s business was essentially and predominantly that of a health and accident insurance company and that the writing of life insurance was rather a minor incident in its general operations. Notwithstanding this, petitioner insists that it is entitled to have its whole business classified as that of a life insurance company, under sections 201-203 of the Revenue Acts, and to receive the benefit of the favorable treatment which Congress has accorded such companies over other insurance companies for income tax purposes.1 Its argument is that the unearned premium reserves which it had set up on its health and accident business were not [950]*950true insurance reserves, in that they were not based upon an experience or actuarial table, did not take into consideration earnings or interest on the fund, and were not used to pay contingent claims when the contingency insured against occurred;2 that such reserves were not required by statutory provision or by rules and regulations of the state insurance department promulgated in the exercise of a power conferred by statute; that section 201(a) of the Revenue Acts, in classifying as a life insurance company any company engaged in writing life insurance, “the reserve funds of which held for the fulfillment of such contracts comprise more than 50 per centum of its total reserve funds”, must be deemed to have had regard only for true insurance reserves required as a matter of state law; that, since the only true insurance reserves which petitioner was required to maintain on any of its insurance business under Missouri law were the death reserves on its life insurance contracts, it was entitled to be classified as a life insurance company under section 201 (a), because the reserve funds which it held for,the fulfillment of its life insurance contracts accordingly comprised more than 50 per cent of the total true reserve funds required of it by law.

It hardly seems reasonable to believe that Congress intended to leave the way open for some other insurance company, such as a health and accident one, to claim to be entitled to have its business taxed as a life insurance company and to escape the burden of taxation upon its premium income generally, through the simple expedient of being authorized and undertaking to write a small and incidental amount of life insurance;3 nor should the statute be allowed to serve such an unnatural purpose, unless its language and implications inexorably compel this construction.

There is nothing in the language itself of section 201(a) that can be said to indicate that, for the purpose of classifying insurance companies generally, Congress was using the term “reserve funds” in the narrow, technical sense in which petitioner seeks • to have it applied. The term “reserves” or “reserve funds” recognizedly has a broader, practical use and significance in the field of insurance than the technical definition for which petitioner contends, and we think that it was in the former, rather than in the latter sense, that it was employed for definition or classification purposes in section 201(a). It is a well known fact, publicized by the insurance companies themselves through financial statements and rating reports, that some form of basic reserve is now customarily set up on all kinds of insurance written on a fixed or stipulated premium basis. This is done as a matter of protective business prudence, as well as for possible competitive purposes, regardless of whether such reserves are specifically required by statute or not.

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Bluebook (online)
128 F.2d 948, 29 A.F.T.R. (P-H) 748, 1942 U.S. App. LEXIS 3764, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-protective-ins-v-commissioner-ca8-1942.